Description
Book SynopsisCapturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
Expert international contributors present an array of perspectives and approaches to research in the field, but all consider the necessity of fundamental reforms. The Research Handbook offers a reappraisal of the foundations and core concepts of the international tax regime, highlighting the need to adjust nineteenth and twentieth century solutions to the challenges of the twenty-first century. Chapters look at the challenges of embracing globalization, the interdependence of world economics, the ensuing impossibility of truly unilateral international tax policy, and the need to accommodate the expanding cast of players on the political map.
With a variety of paths to reform suggested throughout, this Research Handbook will prove an invigorating read for law scholars working on taxation law as well as practitioners and policy makers seeking ways to improve, or navigate, the current state of affairs with international tax law.
Trade Review‘This is an excellent book which includes several thought-provoking analyses. Although the chapters are intended to provide the reader with an “initial reading” necessary for research on the topics, most of these chapters go much further than that. The book explores a wide variety of themes and is not restricted to corporate or tax treaty related ones as are many textbooks on international taxation. This is seen by the reviewer as a strength rather than a weakness—the Research Handbook on International Taxation
helps to fill in a gap in the existing literature. Furthermore, the agenda for further research set out in many contributions is likely to prove very useful to those -- exploring and challenging the current state of affairs.’– Christiana HJI Panayi, British Tax Review
‘On showcasing thoughtful researchers, the collection is a tour de force. Brauner is a brilliant curator. Chapters were contributed by scholars in the US, Spain, Canada, Israel, Germany, Brazil, Italy, the UK, Australia, Serbia, Austria, and Poland. The list is not quite half women, but it’s not far from it. And although most of the contributors are distinguished senior scholars – leaders in their fields – there are a few emerging voices that showcase the promise of the field. The world of international tax is exploding with new players and new ideas. The stakes are higher than ever. And so is the need for a Handbook. Especially one this good.’ -- Kim Brooks, JOTWELL
‘This book constitutes an essential guide for everybody interested in understanding the current challenges the international tax system is facing. Written by leading scholars in the field, it concentrates on key issues in the international tax debate and provides for innovative and well-argued solutions to make the international tax system viable for the 21st century.’ -- Alexander Rust, Vienna University of Economics and Business, Austria
‘The book addresses a wide range of important topics that are treated by knowledgeable authors. Anyone who does serious work in the field of international taxation will want to consult this volume.’ -- Cliff Fleming, Brigham Young University, US
Table of ContentsContents: Introduction to Research Handbook on International Taxation Yariv Brauner xv PART I FUNDAMENTALS 1 Does customary international tax law exist? 002 Reuven S. Avi-Yonah 2 The origins of the international tax regime 013 Sunita Jogarajan 3 International tax organizations 029 Allison Christians 4 Tax discrimination 044 Elizabeth Adams, Michael Knoll, and Ruth Mason PART II DOCTRINAL BUILDING BLOCKS 5 Taxation of employment 065 Pasquale Pistone 6 Taxation of cross-border services 078 Andr.s B.ez Moreno 7 Transfer pricing 097 Aitor Navarro 8 Article 17 force of attraction 120 Karolina Tetłak PART III KEY DEBATES 9 Competition v. cooperation in international taxation 141 Tsilly Dagan 10 The arm’s length standard: justification, content, and alternative proposals 153 Luis Eduardo Schoueri and Ricardo Andr. Galendi J.nior 11 Can law regulate its own interpretation? Relevance and meaning of articles 31–33 of the vienna convention on the law of treaties (VCLT) and article 3 para. 2 of the model convention of the organisation for economic co-operation and development (OECD MC) for the interpretation of double taxation conventions 174 Michael Lang 12 International tax treaty dispute resolution, the mutual agreement procedure, and the promise of mandatory arbitration for developing countries 191 Yariv Brauner PART IV FEEDBACK SYSTEMS 13 The political science of global tax governance 218 Martin Hearson and Thomas Rixen 14 International taxation and international trade: common objectives, different paths, and inevitable clash 239 Monica Victor and Yariv Brauner 15 International taxation and environmental protection 258 Alice Pirlot 16 Research strategies in comparative taxation 278 Carlo Garbarino PART V THE FUTURE OF INTERNATIONAL TAXATION 17 Multilaterallism in international taxation: it is really the future? 317 Juan Zornoza P.rez 18 General thoughts on illicitly obtained information in tax matters 341 Hugo L.pez L.pez 19 International taxation and migrations 353 Svetislav V. Kostić 20 Taxation of robots 369 Joachim Englisch Index 385
